To the Board of Medicine:

I am writing to express my concerns about the proposal to amend the occupational therapy regulations related to Inactive Licensure (18 VAC 85-80-72) and Reinstatement (18 VAC 85-80-80). I encourage the Board to engage in a dialog with the American Occupational Therapy Association and the Virginia Occupational Therapy Association to put in place regulations that are not too onerous for occupational therapy practitioners, but that also protect the public.

In 2005, I returned to the profession after a 5-year hiatus as a family caregiver.  I completed the required professional hours shadowing a licensed Occupational Therapist as well as the required continuing education hours.  That process enabled me to update my clinical skills and readied me to re-enter the profession with licensure in Virginia.  The proposed requirement of re-taking the NBCOT OT exam would have been a massive barrier and a strong deterrent to me in returning to this field.

Requiring someone seeking to rejoin the profession whose license has been lapsed for only 2 years to show a current NBCOT certification or retake the exam is a lot to ask of someone who might be switching jobs after working in another state or recovering from an illness or family emergency. Thank you for your consideration.

Sincerely,

Cynthia Webster OTR/L